On April 2 and 4, John Erickson participated on behalf of APGA in a meeting of the Distribution Contractor’s Association (DCA) Operator Qualification Integrity Program (OQIP) task force in Nashville. In 2016, the DCA established this task force to investigate whether and how the industry can improve the OQ process and provide more consistency in compliance with operator qualification (OQ) programs, specifically requirements for contractors working for operators. Under the OQ rule, pipeline operators are held responsible for compliance with the OQ rule, so they often insist that contractors who work on their pipeline meet their strict requirements, without exception, even though the contractor personnel may have already completed training and passed OQ evaluations to perform the same covered tasks for other operators. The end goal of OQIP is to develop and promote a consistent and standardized OQ process so that operators who use contractors can feel comfortable accepting evaluations performed by others rather than require those contractor personnel to begin OQ from the beginning. A major component of the OQIP is processes to ensure the integrity of evaluations, both tests and hands-on demonstrations.
The work of the task force has evolved from a discussion of several OQ-related issues by an ad hoc group of interested stakeholders to a structured and chartered coalition consisting of DCA contractors, OQ service providers, industry consulting groups, subject matter experts and regional gas associations who represent gas utilities from all areas of the nation.
A draft OQIP was developed in 2018 and in the past six months, operators in New Mexico, Washington and Michigan have been pilot testing the OQ procedures with their contractors. At this recent meeting, the task group heard from several contractors involved in the pilot program. A major concern was that meeting the requirements of the OQIP would significantly increase the cost of qualifying individuals, which is a major concern for contractors whose workforce is constantly changing.
The OQIP is not intended to be the basis of future regulation. While increasing consistency and standardization will result in “raising the bar” by going above and beyond current regulation, this will be achieved by voluntary actions overseen by program participants.
For more questions on this article, please contact John Erickson at
jerickson@apga.org.